The liquidators of former Rangers football club and the Murray group companies are to appeal against the recent decision of the Scottish Court of Session that found that EBT loans were actually remuneration.

Last month three judges decided in favour of HMRC in their long-running battle with the Murray group and the former Rangers football club over its Employee Benefit Trusts (EBT). Payments made to executives, players and their families via the EBT were deemed remuneration and not loans.

Murray Group executives and football players were all 'paid' via loans from the club's EBT for nearly ten years from 2002 in a scheme designed to avoid PAYE and NICs.

Players were contracted by the club for comparatively low salaries but under the terms of a 'side letter', the club paid cash bonuses into its EBT which in turn appointed the cash into various sub trusts for the players and their family. Players contracts had to be registered with the Scottish Football Association, however the side letter was not disclosed.

A report by BBC Scotland last Monday quotes Rangers' liquidators BDO who say:

"Following discussions with the company's legal advisers and the liquidation committee, the joint liquidators have filed an application seeking leave to appeal the Inner House of the Court of Session decision in respect of the EBT case.

"If the company successfully obtains leave to appeal, the appeal will be heard in the Supreme Court in London.

"The joint liquidators are not in a position at this stage to make any further comment in respect of the appeal."